“There has been a lot of attention and discussion in the past few weeks regarding the physical security of our electric infrastructure. I first want to thank Chairman LaFleur for her leadership and for directing our staff to conduct meetings with NERC and industry. With many meetings taking place across the electric sector on this issue, I believe it is important that we all engage in this discussion and share our thoughts.

“Vigilance with regard to grid security is imperative in today’s world. Our electric grid and the supply of electricity are essential to our economy and the health and safety of Americans. From the 2003 blackout to Hurricane Sandy, I believe there is even greater awareness of this today.

“Comments from senior defense officials and other high ranking government officials have made us aware of the threat facing America from cyber-attack. Geomagnetic disturbances, electromagnetic pulses, and natural disasters also threaten grid stability and could cause large scale outages.

“We have over 400,000 circuit miles of transmission in North America and 55,000 transmission substations. The vulnerability of our grid infrastructure to physical attack is a decades-old reality.

“The electric utility industry has always placed a high value on reliability. With Section 215 added to the Federal Power Act through the Energy Policy Act of 2005 giving us the Electric Reliability Organization and mandatory standards, we have made significant progress on grid reliability.

“However, I speak today to express my concern that we channel our resources and efforts to physical security in the same manner that we have focused our efforts on the long list of other threats to our grid.

“We have already been taking a number of steps to address our vulnerability to physical attack that will prepare us for multiple reliability and security events. Such steps include a focus on defense-in-depth, drilling and simulation exercises like NERC’s two day drill last November, and increased communication across the industry and with law enforcement agencies.

“To address physical vulnerability, it is also important to focus our efforts on modernizing our electric grid. Building the grid of the future will play a key role in addressing multiple security and reliability threats or situations. We should look to further deployment of phasor measurement units, wide-area management systems and enhanced situational awareness. Furthering efforts in the development and deployment of microgrids and smart grid technology will also greatly assist in addressing grid resiliency. These efforts, along with system-wide planning, are just a few examples of how we can increase our ability to make the grid more reliable and efficient.

“My concern is that many people have jumped on the reaction train here with regard to the Metcalf incident. While I do not mean to disregard that incident in any way, I would remind everyone that it is an isolated incident, no conclusions have been drawn from experts in law enforcement regarding the nature of the attackers, and power was not interrupted. To my knowledge no information exists at this time that the Metcalf incident is an indication of any future planned attacks.
“Yet, elected officials and our former colleague seem to be calling for significant measures specifically geared toward erecting various physical barriers to our grid infrastructure. I am concerned that such actions are a 20th century solution for a 21st century problem.

“While there may be some locations where it may be reasonable to increase physical barriers to existing infrastructure, I caution against over-reaction in this area. In one recent meeting I had with just three public utilities, it appears that they alone could be on course to spend more than $500 million on physical barriers and increased security measures around transformers and substations.

“Our future is in building a smarter and more nimble grid along with better communication and coordination to mitigate against multiple forms of risk including those I have mentioned above.

“I believe it is more prudent, and greater overall security will be achieved, if we move forward with the meetings being planned with NERC and stakeholders. These meetings should focus on developing plans for system-wide security with a multi-functional approach that encompasses the vision of the grid of the future. We should be cautious about expending valuable time and resources, not to mention piling up billions in consumer costs in rate base, with the deployment of walls and fences.

“If we learn more from law enforcement officials, we should reassess appropriate actions at that time. But with 400,000 miles of transmission lines and 55,000 substations, the strategy should be focused on a multi-functional, intelligent grid that is resilient and capable of mitigating multiple kinds of threats. That same grid will also enable us to tackle other issues such as the integration of intermittent resources, increasing demand side management capabilities and more.”